What is a privacy notice & why is it important?
We know your personal information is important to you and it is important to Irish Life Health too. This Privacy Notice tells you what we use your personal information for and explains your rights around how we use it. Please read this Privacy Notice to understand how and why we use your personal information.
If you give us personal information about someone else, please make sure you have their permission and please make them aware of this Privacy Notice, as it also applies to them.
What information we collect and why
We use your personal information and the personal information of other members on your plan to provide you with health insurance plans, customer service and to assess and pay claims. This personal information includes but is not limited to, your name, date of birth and contact details.
If we collect any sensitive personal information, we will restrict access to, and use of this. Please note that if you give us false information or fail to disclose information, we will record this.
We must have a lawful basis to collect and use personal information, the below sets these out:
Needed for your contract
Personal information about you and other members on your plan (as referenced above) is held and used to:
- process your application
- issue your plan
- provide you with information about your plan
- make and receive payments to you and from you
- provide customer care and service
- contact you to inform you of any relevant actions you may need to take
- administer your plan and pay claims. We have an automated system in place for Online Day to Day claiming which allows you to submit your claims online and get paid directly into your bank account. You can however, request that a person make the decision on your claim.
We also collect and use personal information about insurance brokers to service their agency contracts with us.
Required by law
We use your personal information to comply with law and regulations for example:
- reporting to regulators
- keeping proper books and records
- actuarial claims analysis and risk management to ensure the company stays financially sound
- we may in certain circumstances share your personal information with other health insurers for the purposes of verifying your lifetime community rating loading information and determining waiting periods to the extent permitted by law.
- we are also required to screen all customers against Financial Sanctions lists and to do this we will use your name, date of birth and address.
- if we provide you with advice we are required to complete an analysis of your health insurance needs to ensure that we recommend a health insurance plan that is the most suitable for you
We carry out internal reporting, quality checking, compliance controls and audits to help meet our legal obligations.
If you visit our offices we will record CCTV footage for safety and security reasons. We only hold these recordings temporarily and for longer if we need to for safety and security investigations.
Irish Life Health’s legitimate interest
We use your personal information for our legitimate interests as shown below. We have taken account of any privacy risks and ensured that your data protection rights are not affected. We believe these uses benefit our customers. You can contact us if you have any questions using the details in section 8 of this Privacy Notice.
We may, on occasion look for information from your GP, consultant, hospital or other medical provider regarding any treatment provided to you or other members of the insurance policy. A clinical audit is undertaken to understand the appropriate use of resources and the resulting outcome and quality of life for patients.
With your consent
You need to give consent for us to collect and use personal information for certain uses. You are given the choice to provide consent, or not. When we collect your consent, we will explain what we need it for and how you can change your mind in the future.
We would like to be able to contact you about offers and services from Irish Life Health and our group of companies, separately from your plan communications. We will only send you direct marketing content where we have your consent.
Where you have already indicated a preference, this will remain unless you subsequently contact us to change this.
Consent and how to withdraw consent?
If we process your personal information based on consent, you have the right to withdraw that consent at any time. The opt-out methods will depend on how the consent was collected and will be explained when you give us your consent, e.g. you can change your mind using the opt-out link in any direct marketing emails sent to you.
You will also be able to withdraw consent by contacting us directly using the details in section 8 of this Privacy Notice.
How and where do we get your personal information from?
You provide us with your personal information (and the personal information of other members on your policy) directly when you contact us, complete our forms, speak with us or visit our website, social media accounts and mobile apps. For more information on what personal information is collected and used on our website please see our Cookies Policy at http://www.irishlifehealth.ie/privacy-and-legal/privacy-statement/.
We also get personal information from insurance brokers, solicitors, employers, regulators, GPs, consultants, hospitals or other medical providers as and when required.
Who do we pass your personal information to?
Companies that act as service providers under contract with us and only process your personal information as instructed by us. Your personal information is transferred securely and is not used by other parties for any other reason. The categories of services that we use other Data Processors for include: document management, administration, customer services, marketing, and financial sanctions list screening.
In certain instances, we may need to collect personal information, including medical or other sensitive personal information, from third parties about you and any other member named on your policy. This information will remain strictly confidential and will only be sought and used in order to provide the services set out in your contract with us and for administration of your plan.
Do we transfer it outside of the EU?
Your personal information is processed and stored within the EU. However we do pass personal information securely to our parent company Great West LifeCo in Canada. This is used for screening our customers against financial sanctions lists to comply with relevant legislation.
Passing your personal information to certain countries, including Canada, is allowed under an adequacy decision made by the European Commission. This means you have the same standards of protection as you have within the EU. As our parent company, Great-West Lifeco has a legal obligation to maintain a record of this screening.
How long do we keep it for?
We keep and use your personal information for as long as you have a health insurance contract with us. We also hold it after this where we are required to by law for example where we need to for complaints handling and for system back-ups needed for disaster recovery.
We will let you know how long we keep personal information for when you avail of a specific service such as a quote or call-back on our website.
What are your rights?
You have a number of rights over your personal information which you can exercise free of charge by contacting us using the details in section 8 of this Privacy Notice. You will need to give us information to help us identify you and we will respond to you within one month. Any restrictions to your rights will be explained in our response.
Right to Information
You have a right to the information set out in this Privacy Notice.
If we make changes to the type of personal information we collect and / or how we use it, we will inform you of the changes. We have controls in place to protect your personal information and minimise the risk of security breaches, however, should any breaches result in a high risk for you, we will inform you without delay.
Right to Restrict or Object
You can restrict or object to any unfair and unlawful collection or use of your personal information. You can object to any automated decision making that has a legal or similar significant impact for you and ask for the decision to be made by a person. Where you have previously provided consent, you can withdraw it at any time.
Right to Correct and Update
You can ask us to correct and update personal information we hold about you; to provide you with the best service it is important we have your up to date personal information, such as contact details.
Right to Delete and Be Forgotten
You can have your personal information deleted if it is incorrect or has been processed unfairly or unlawfully.
If you have withdrawn consent you can ask for your personal information to be deleted. We will keep a record of your request so we know why your personal information was deleted.
If we have provided a regulated product or service to you, we must keep your personal information for minimum periods required by law.
Right to Access
You have the right to know what personal information we hold about you and to receive a copy of your personal information.
We must tell you:
- why we hold it,
- who we pass it to, including whether we transfer it outside the EU,
- how long we keep it for,
- where we got it from; and
- if we carried out any automated-decisions, and if so, the logic behind it and what it means for you.
To access your personal information please write to us using the contact details in section 8 of this Privacy Notice. To help us respond as quickly as possible please let us know if you are only looking for copies of specific personal information.
You may also request a copy of personal information held by us in an automated format, that you gave us, including through your interactions with us. You can receive this in a machine readable format that allows you to keep it. You may also request Irish Life Health to send this personal information in a machine readable format to another company. The format will depend on our ability to provide this in a secure way that protects your personal information.
How to contact us
You can contact with any questions about your personal information and this privacy notice:
Irish Life Health
Block D, E, F
Lower Abbey Street
Irish Life Data Protection Officer
Irish Life Health also has a Data Protection Officer that you can contact directly:
Irish Life Health Data Protection Officer
Irish Life Health
Block D, E, F
Lower Abbey Street
If you do not think that we have processed your personal information in line with this Privacy Notice, please contact us.
If you are not happy with how we have processed your personal information or handled your privacy rights, you can complain to the Data Protection Commission by contacting them below:
Data Protection Commission,
Canal House, Station Road,
Co. Laois, R32 AP23
+353 761 104800
1890 252231 (LoCall)